Privacy Policy

Asterminds K.K. ("the Company," "we," "us," or "our") operates the organizational-knowledge analytics platform available at astermindsjp.com (the "Service"). This Privacy Policy explains how we collect, use, store, and protect personal information in connection with the Service, in accordance with Japan's Act on the Protection of Personal Information ("APPI"). Please read this policy before using the Service.

1. Business Operator

Asterminds K.K. (2-11-1 Shibuya, Shibuya-ku, 18F, Tokyo 150-0002, Japan) is the personal information handling business operator under APPI with respect to personal information collected through astermindsjp.com.

The Company's core service involves processing organizational data submitted by enterprise clients. This includes communications metadata, project-record summaries, and HR-system exports that client organizations make available to the Company for the purpose of building organizational knowledge graphs and expert-finder outputs. Enterprise clients remain the primary data controllers for their own employees' data; the Company acts as an operator processing that data under each enterprise's instructions and applicable data processing agreements.

Contact for personal information inquiries: [email protected]

2. Categories of Personal Information We Handle

The Company handles personal information in two distinct contexts:

Website visitors and prospects: When you visit astermindsjp.com, submit a contact form, or apply for early access, the Company may collect:

• Identity and contact information you submit directly (name, work email address, company name, role title);
• Content of messages and inquiries you send to us;
• Technical information collected automatically (IP address, browser type, pages visited, session duration);
• Analytics data collected with your acknowledgment under our notice-only cookie model.

Enterprise platform data: When an enterprise client connects data sources to the Asterminds platform (HR information systems, project management platforms, collaboration tools, document repositories), the Company processes employee-related organizational data on behalf of that enterprise. This may include employee names, job titles, department assignments, project participation records, and communications metadata (such as sender/recipient/timestamp patterns used to infer collaboration relationships). The Company does not read the substantive content of private communications beyond what is necessary to build the organizational knowledge graph as configured by the enterprise client.

The Company does not use organizational data submitted by enterprise clients to train machine-learning models without prior explicit written consent from the enterprise client.

3. Purposes of Use

The Company uses personal information for the following purposes. We will not use information beyond these purposes without your prior consent, except as permitted by APPI.

For website visitors and prospects:

• To respond to inquiries, demo requests, and pilot applications;
• To communicate information about the Service that may be relevant to your inquiry;
• To operate, maintain, and improve astermindsjp.com;
• To meet legal and compliance obligations.

For enterprise platform data:

• To build and maintain organizational knowledge graphs for the enterprise client;
• To generate expert-finder results, organizational topology maps, and HR analytics outputs as contracted;
• To provide technical support and customer success services to the enterprise client;
• To detect and prevent unauthorized access or misuse of the platform;
• To comply with legal obligations applicable to the Company.

4. Provision to Third Parties and Cross-Border Transfers

The Company provides personal information to third parties only in the following circumstances:

• To processors (subcontractors) acting on our behalf, such as hosting infrastructure providers and analytics services, under appropriate supervision and data processing agreements that restrict the processor's use of the data;
• Where required by applicable law, regulation, or a court order;
• With your prior explicit consent.

Where personal information is transferred to processors or recipients located outside Japan, the Company obtains prior consent from the data subject and provides information about the recipient country's personal information protection framework, as required by APPI Article 28. Enterprise clients are informed of any cross-border sub-processing in their data processing agreements. The Company maintains records of such transfers as required by APPI.

The Company does not sell personal information to third parties.

5. Retention

The Company retains personal information for as long as is necessary to fulfill the purposes described in this policy, and no longer. Specific retention guidelines:

• Inquiry and contact data: retained for up to three years from the date of last contact, or until you request deletion;
• Early-access application data: retained for the duration of the evaluation and for one year thereafter unless a contract is entered;
• Enterprise platform data: retained for the duration of the applicable enterprise contract, plus any retention period required by Japanese law or agreed in the enterprise contract, after which it is securely deleted or returned to the client as agreed.

6. Security

The Company applies technical and organizational measures proportionate to the nature and volume of personal information handled. Enterprise platform data is processed within Japan-resident infrastructure. Access controls, audit logging, and encryption in transit are applied to the platform. The Company conducts periodic internal reviews of its security practices.

7. Your APPI Rights

Under APPI, individuals whose personal information is handled by the Company have the following rights with respect to retained personal data:

• Right to disclosure of retained personal data held by the Company;
• Right to correction, addition, or deletion where the information is factually inaccurate;
• Right to cease use or erasure where the information is being used for purposes beyond those notified, or was obtained unlawfully;
• Right to cease provision to third parties where the provision does not meet APPI requirements;
• Right to disclosure of records of provision to third parties.

To exercise any of these rights, email the Company at [email protected] with your request and sufficient information to identify the personal data concerned. The Company will respond promptly and without undue delay. We may request identity verification before processing a request to protect against unauthorized disclosures.

Note: for rights requests relating to personal data held as part of an enterprise platform engagement, the Company may need to coordinate with the relevant enterprise client, which retains primary controllership over its employees' data.

8. Complaints

If you believe the Company has not handled your personal information in accordance with APPI, you may file a complaint or inquiry with the Personal Information Protection Commission of Japan at ppc.go.jp.

We encourage you to contact us directly at [email protected] in the first instance; we are committed to resolving concerns quickly.

9. Cookies and Tracking

The Company uses cookies and similar technologies on astermindsjp.com. For full details of the cookies used, their purposes, and how to manage them, see our Cookie Notice.

10. Changes to This Policy

The Company may update this Privacy Policy from time to time to reflect changes in the Service, applicable law, or the Company's practices. Material changes will be posted at this page with a new "Last updated" date. We encourage you to review this policy periodically.

11. Contact

Asterminds K.K.
2-11-1 Shibuya, Shibuya-ku, 18F
Tokyo 150-0002, Japan
Email: [email protected]
Phone: +81 3 6809 1240